Customs Act sentencing minimum applied where no special and adequate reasons justified a lower term for prohibited goods conviction.

Sentence under Section 135(1)(i) of the Customs Act was confined to the quantum of punishment, as the conviction was not challenged on merits. The offence was treated as one involving prohibited goods, carrying imprisonment up to seven years, but the proviso required a minimum of one year unless special and adequate reasons justified a lesser term. As no such reasons were recorded by the trial or appellate court, the sentence was reduced to the statutory minimum. The conviction remained undisturbed.

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Issues: Whether the sentence imposed for conviction under Section 135(1)(i) of the Customs Act, 1962 required reduction to the statutory minimum in the absence of special and adequate reasons.

Analysis: The conviction was not assailed on merits and the challenge was confined to the quantum of sentence. The offence was treated as falling within the provision dealing with prohibited goods, for which imprisonment may extend up to seven years, but the proviso mandates a minimum sentence of one year unless special and adequate reasons are recorded to justify a lesser term. As neither the trial court nor the appellate court recorded such reasons, the sentence was fit to be brought down to the minimum prescribed by the proviso.

Conclusion: The sentence was reduced to one year's imprisonment while the conviction was maintained.

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